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The Integrity Vice Presidency (INT) is an independent unit within the World Bank Group that investigates and pursues sanctions related to allegations of fraud and corruption in World Bank Group-financed projects. INT supports the main business units of the World Bank Group and external stakeholders, mitigating fraud and corruption risks through sharing investigative findings, advice, prevention and outreach efforts.

INT's FY2018 Annual Report details the World Bank Group’s ongoing commitment to fighting fraud and corruption, which is an integral part of the World Bank's efforts to end extreme poverty and boost shared prosperity.

EVENTS

External Investigations

Complaint Intake

INT performs an initial assessment of every complaint that it receives. This assessment determines whether: the complaint relates to a sanctionable practice in World Bank Group-financed projects, the complaint has credibility and the matter is of sufficient gravity to warrant an investigation. Complaints outside of INT's jurisdiction are redirected to other areas of the World Bank Group as appropriate. Complaints that fall under INT's jurisdiction are investigated if they are determined to be of a higher priority. When a complaint does not reach this threshold, INT works with Operational staff to address the issues raised. In assigning priority, INT also considers the possible reputational risk to the World Bank Group, amount of funds involved and quality of the information or evidence in INT's possession.

Investigation of Cases

Through investigations, INT ascertains whether firms and/or individuals have engaged in one of the World Bank Group's five sanctionable practices. Since an INT investigation is administrative in nature, the standard of proof is akin to a "balance of probabilities" and therefore lower than the criminal standard of "beyond a reasonable doubt." The World Bank Group, for that reason, has to prove that it is more likely than not that the alleged misconduct has occurred. If INT finds sufficient evidence to prove the allegation, the allegation is considered substantiated. The allegation is considered unsubstantiated if there was insufficient evidence to prove or disprove it, and unfounded if the allegation has no basis in fact.

Investigation Reports

When INT substantiates a case, it produces a Final Investigation Report (FIR). In some cases, INT will produce an FIR even if there is not reasonably sufficient evidence to substantiate a complaint - for example, if INT believes that the investigation unearthed important lessons that should be shared with colleagues in the World Bank Group. FIRs are sent to regional management for comment before being finalized and provided to the World Bank Group President.

INT strives to ensure that the maximum time between opening a case and completing an investigation report is twelve (12) months for normal cases and eighteen (18) months for complex cases.

FIRs also form the basis for two other INT outputs: referral reports, which INT sends to relevant national authorities if evidence indicates that the laws of a World Bank Group member country may have been violated; and redacted reports, which are provided to the World Bank Group's Board of Executive Directors and, after the completion of any related sanctions proceedings, posted on this site.

Internal Investigations

To maintain its credibility in the global anti-corruption arena, the integrity of the World Bank's own operations is of the utmost importance. In addition to investigating allegations of fraud and corruption involving Bank Group staff and corporate vendors, the Internal Investigations Unit mainstreams lessons learned through case studies, training and other activities and participates in outreach programs as a member of the Bank Group's Internal Justice System to promote the reporting, detection and prevention of fraud and corruption within the Bank Group's corporate arena.

Examples of allegations against staff within the Internal Investigations Unit's investigative mandate include abuse of position for personal gain, misuse of Bank Group funds or trust funds, embezzlement, fraud, corruption and collusion, involving either Bank Group operations or in the administration of Bank Group business, and attendant conflicts of interest or lesser included acts of misconduct.

The Internal Investigations Unit is also responsible for investigating allegations against Bank Group corporate vendors involving fraud, corruption, collusion, coercion, or obstructive practices in support of "vendor eligibility reviews," leading to corporate debarment proceedings.

REPORT SUSPECTED FRAUD OR CORRUPTION

Concerned about fraud or corruption in World Bank Group-financed projects?

Sanctions

When firms or individuals are found through an INT investigation to have engaged in fraudulent, corrupt, collusive, coercive or obstructive practices, the World Bank Group may impose a sanction such as debarment. Debarred entities are then ineligible to be awarded a World Bank Group-financed contract, either permanently for a designated period of time. Sanctions hold wrongdoers accountable for their misconduct and help deter others from engaging in similar behavior.

Compliance

Conditions for Release from WBG Sanction

Debarment with conditional release was established as the baseline WBG sanction, in part, to place greater emphasis on rehabilitation, such as by requiring sanctioned entities to develop and implement integrity compliance programs that are consistent with the principles set out in the WBG Integrity Compliance Guidelines also available in Arabic, Chinese, French, Korean, Portuguese, Russian and Spanish. In addition to serving a rehabilitative purpose, the implementation of such a program also seeks to reduce the likelihood of the sanctioned entity engaging in fraud or corruption in the future.

Engagement with WBG Integrity Compliance Office

Invitation: All parties sanctioned with conditions for release come into the WBG Integrity Compliance Office portfolio, regardless of how the sanction was imposed. Following the imposition of such a sanction, the Integrity Compliance Office invites the sanctioned party (entities and individuals) to engage with it in working toward satisfaction of such conditions.

Steps: In engaging with a sanctioned entity, the Integrity Compliance Office first seeks to understand matters such as the entity’s: (i) size; (ii) corporate structure; (iii) organizational structure; (iv) operating model; (v) geographical areas of operation; (vi) sectoral areas of operation; (vii) risk profile; and (viii) existing integrity compliance-related controls (including any integrity compliance program). Throughout the engagement, the Integrity Compliance Office works with the sanctioned entity, as well as independent integrity compliance monitors/advisors in some cases, to recommend enhancements to and assess the effectiveness of the entity’s integrity compliance-related controls.

Determination: In determining whether a sanctioned entity has met its conditions for release, the Integrity Compliance Officer assesses whether it has put in place integrity compliance-related controls that: (i) are tailored to its risks and profile; (ii) are consistent with the principles set out in the WBG Integrity Compliance Guidelines; and (iii) have a demonstrated record of implementation.

Collective Action

The ICO also encourages sanctioned parties, as well as released parties, to promote collective action for the advancement of integrity principles, such as through participation in workshops and mentorships.

The Summary of World Bank Group Integrity Compliance Guidelines incorporates standards, principles and components commonly recognized by many institutions and entities as good governance, and anti-fraud and -corruption practices. They are not intended to be all-inclusive, exclusive or prescriptive; rather a party's adoption of these Guidelines, or variants thereof, should be determined based on that party's own circumstances.

REPORT SUSPECTED FRAUD OR CORRUPTION

Concerned about fraud or corruption in World Bank Group-financed projects?

Preventive Services Unit (PSU) was created in January 2008 in response to calls from staff in Operations for relevant, specific advice and assistance in the design of their projects, using lessons learned from the Integrity Vice Presidency's (INT) investigative and diagnostic work.

The creation of a preventive services unit was a key recommendation of the Indepent Panel Review of INT to share best practices in preventing and mitigating risk of fraud and corruption in Bank financed-projects.

The Preventive Services Unit turns the unique knowledge gained from INT investigations, diagnostic and analytical activities into practical advice and training on how to prevent corruption in World Bank-financed projects.

PSU's main objective is to help improve the integrity of Bank Group-supported activities and to enhance the development impact of Bank Group operations by working closely with task team leaders and members in designing pragmatic measures that can mitigate against fraud and corruption risks in projects.

Publications

Taking a more comprehensive approach to targeting fraud and corruption, INT provides World Bank Group staff and clients with guidance on how to build preventive measures into projects.
The Preventive Services Unit (PSU), working in partnership with operational teams, turns the unique knowledge gained from INT investigations into practical measures that can deter or stop corruption in World Bank Group-financed projects.

This is a study by investigators, for investigators. It focuses not on the big picture but on the small details. It follows a typical procurement process and details the corrupt negotiations and transactions that take place and that have been discovered during investigations. It reports on indicators at all stages that investigators should look for and act on.

This report covers global corruption trends in the roads sector and includes recommendations based on the experience of developed and developing countries. It draws from what INT has learned from its investigations of World Bank Group-financed roads projects; borrowing country governments' investigations and reports; and the experience of developed countries.

RELATED

Annual Reports

INT's FY2017 Annual Report details the World Bank Group’s ongoing commitment to fighting fraud and corruption, which is an integral part of the World Bank's efforts to end extreme poverty and boost shared prosperity.

INT focused on finding the right balance among the many competing anti-corruption priorities. In doing so, INT generated better results in its core investigative and sanctioning work while also helping Bank clients see and prevent the dangers of corruption.

As in recent years, the successes INT had in FY11 have benefited from partnerships at varying levels of government and society, and has coincided with demand from the Bank's client countries for anti-corruption support.

INT managed a case load that spread across 84 countries and 260 projects, all while closing investigations well under targeted timeframes. As a result of INT's investigative work, the Bank Group debarred 45 firms, individuals and non-governmental organizations in FY10.

Stakeholders around the world - including our member countries and donors - are looking to the World Bank Group for leadership in responsible business practices. They expect us to uphold a high standard of integrity in all aspects of our work.

Milestones from FY08 include the implementation of the Volcker Review Panel recommendations for INT; the completion of INT's largest undertaking, the India health sector Detailed Implementation Review; the public release of redacted INT investigative reports; and the arrival of INT's first Vice President.

Among the success stories of FY07 is the support INT provided to the development of a risk assessment and mitigation plan for the Colombia La Guajira Water Project. The Task Team had developed a rigorous governance risk assessment and mitigation plan that received strong and explicit support by a wide range of Board members.

One overarching finding from the investigations into fraud and corruption in Bank-financed projects is that the schemes devised by the corrupt actors are broadly similar whether in Africa, Asia, Europe, Latin America or the Middle East.

Since its establishment in April 2001, the Department of Institutional Integrity (INT) has handled over 1,300 cases and currently has over 300 active cases. The Bank now has a budget of US$10 million for work in this area, making it by far the leader in resources committed among international institutions in the fight against fraud and corruption.